Joint Committee on Draft Communications Bill Report


Report by Peter Kiddle OBE, Specialist Adviser on Radio and Radio Spectrum Issues in relation to the draft Communications Bill


    1. Background
    2. Value of Radio to the National Economy
    3. Spectrum Management
    4. Spectrum Trading
    5. The Cave Report
    6. The Spectrum Efficiency Scheme
    7. Interference Management and Enforcement Powers
    8. International Responsibilities
    9. OFCOM relationship with Users and Industry
    10. Radio Research
    11. Conclusions and Recommendations
    12. Final Comments

Radio and Radio Spectrum Issues


I believe that many of the services that utilise the radio spectrum are not generally appreciated and to assist the committee with their deliberations I hope this very brief background will be helpful.

Radio Spectrum in the civil environment has been used in what I would define as three specific categories, namely:-

Wire less applications where no other technology other than radio could provide the service. Into this category falls mobile radio, satcoms including location services, aeronautical and navigational services, maritime and also broadcast, in particular to mobile receivers. In additions such activities as radio astronomy, radio sciences and amateur radio cannot operate in any other mode.

A second category is where radio technology is a more competitive option both economically and strategically. Typical examples here are telecom and video services to rural or low population densities where the cost of fibre would be uneconomic. Additional the flexibility gained from rapid installation of radio and its transportability are frequently key factors. These benefits are used and will continue to be used to quickly establish new major networks with the possibility of transferring to fibre when the network is established and it is economically viable to do so.

The third category of the use of radio technology is where radio underpins other transmission technologies, namely cable networks, where it may be used as the last mile delivery solution or acts as the prime standby transmission path in the case of cable failure.

Looking to the future Ultra Wideband (UWB) for the business sector and broadband internet access services to the home are ideal candidates for radio solutions to solve the 'last mile drop' problem but their requirements for spectrum bandwidth are quite large. The Nervewire Report and the Scenario Planning examine the future requirements on the spectrum and can be accessed on the RA website and the much discussed convergence of voice, data and video only stress the need for fundamental examination of spectrum management methodologies and OFCOM must be given the power to resolve this major issue.

The likely four future scenarios at the present time are considered to be Internet Convergence, Total Mobility, Digital Islands, Broadband Revolutions.

2.Value of Radio to the National economy

In appreciating the importance of radio as an essential and growing high technology transmission medium it is frequently not realised its importance to the National economy. It is included here to help complete the overall picture of the radio spectrums significant importance. Estimates by a number of sources place the value of the radio industry(excluding civil aviation, defence and other public sector use of radio) at some 20 billion pounds per annum at 2000 prices. Broadcasting and public mobile radio together account for approximately 75% of the estimated benefits to the economy.

3. Spectrum Management

Radio spectrum technical management includes the harmonisation and allocation of radio spectrum which should reflect the harmonisation requirements of the general policies of both the EU and ITU. However the spectrum technical management at the International/European level does not cover assignment and licensing procedures which remains a national responsibility and it is in these areas where OFCOM need to ensure that maximum usage is made of existing allocations to ensure minimum restraints are placed on establishing new competitive and innovative services. Spectrum Auctions, Spectrum Trading and Spectrum Re-Farming will all play their part in spectrum management. Technical benefits in spectrum management will remain under constant review if we are to benefit from future technological advances and react accordingly

4. Spectrum Trading

Although this is seen as another market driven spectrum management regime the details of how it will be implemented are not totally clear at this stage. However even though the traded licence will in principle be to identical conditions to the those applied to the original licensee there are likely to be improved technology techniques used by the new owner that could have interference repercussions.

5.The Cave Report

The report examines the spectrum management issues from both the economic and political viewpoint whereas I have expressed my concerns purely on whether the bill ensure the right level of technical/engineering requirements. Both approaches achieve the same findings namely that the major areas of concern and challenges for the future are:-


  International Co-ordination

  Demands for new services

All of these issues will involve considerable engineering expertise to arrive at a satisfactory way forward.

6.The Spectrum Efficiency Scheme

This scheme is in principle approved by both DTI and the Treasury and provides the opportunity for individuals or research organisations to put forward project proposals that meet the requirements of the scheme in measuring the economic/technical benefits by achieving better spectrum efficiencies.

This could be in either specific frequency bands or systems applications which if approved would be financed by the scheme. The administrative responsibility will be OFCOM and consideration should given to its reference in the Bill as this is a unique opportunity to encourage and support innovative research where economic benefits can be forecast.

7. Interference Management and Enforcement Powers

Interference management can be a controlling factor in managing spectrum and the defining of the wanted to unwanted radio signal ratio is a key parameter used by regulators in the modelling and planning criteria of fixed networks. In the future if this planning ratio can be reduced for new systems providing services more immune to interference then the spectrum can be used more efficiently allowing new services to be introduced in existing allocated bands. Additionally the ability of modern equipment design to dynamically handle interference will further allow higher wanted to unwanted signal ratios to be used.

Although the Cave report suggests that much of the responsibility for managing interference in a given allocation could be transferred to the operator OFCOM should remain responsible for setting and monitoring minimum mandatory guidelines for this vital requirement. This planning process of the wanted to unwanted signal requirement is to ensure that co-channel and adjacent channel interference from system to system will not produce a degradation to the quality of service provided as against interference arising from the illegal use of the spectrum by unlicenced operators. This later situation has to be resolved through the RA investigation and enforcement unit. It is important to understand that it is frequently assumed that this later type of interference is limited to 'pirate radio' station operators although in practice, for example, the aeronautical and maritime frequency bands suffer this illegal usage where its effects can be extremely serious where safety of life could be at risk.

To help in this area, the RA have well established regional offices and customer panels set up, to work closely with operators and industry and it is important that OFCOM maintain these activities. Although the Bill suggests stronger enforcement powers it is difficult to predict the increase in illegal spectrum usage and the effectiveness of the presently proposed powers may need to be kept under review by OFCOM.

Finally with greater future flexibility and ease of access to the spectrum it will be necessary for OFCOM to pay further attention to interference management. Additionally the effects of spectrum trading where different technologies could be used, whilst complying with the original licence conditions could require further control by OFCOM. The Bill should, in my opinion, specifically refer to this OFCOM responsibility for interference management and not be covered by the statement of their general duties.

8. International Co-ordination

The Government has a clear obligation as a signatory to a number of Treaties in relation to Technical Spectrum Management at both the European and International level. Where future spectrum harmonisation allocations, reviews of the international Radio Regulations and new Standards are being created, it is vital that the UK take full participation in the work. The necessary preparation for World Radio Conferences (WRC) can take 2/3 years and unless the UK arrive at the conference with sound arguments and justifications for their proposed spectrum demands then many of our future plans could be jeopardised.

In the creation of OFCOM this would appear to be an area which should be specifically defined as an OFCOM duty. There would appear to be some difficulty here between the responsibilities of the RA and DTI itself which will need some detailed clarification when the RA will no longer be a Government agency. The importance of the international co-ordination work cannot be underestimated if the UK is to benefit from future spectrum allocations and harmonisation. I believe the Bill does not adequately cover this issue and I would suggest the committee gives some consideration to suggested wording in the recommendation section of this report. The additional question here is should areas such as international co-ordination and the fulfilling of our radio frequency monitoring service, to which the UK are a signatory to the RF monitoring Treaty, remain as a government agency or become an OFCOM responsibility.

9. OFCOM - Relationship with Industry and Operators

In the past both Oftel and the RA have had wide ranging joint committees with Operators, Industry and Academia which have a record of resolving many difficult issues. Although the establishment of such relationships with OFCOM could be considered an OFCOM management issue I believe for those outside of OFCOM would like to see it as their right to participate in such a forum. The committee may therefore wish to consider the inclusion of such a duty within the Bill. This is particularly important where the UK is represented in International fora by representatives from all sectors.

10. Radio Research

Research referred to here is purely technical and engineering research and in no way covers the necessary market or economic research activities that OFCOM will no doubt be required to carry out as part of their normal duties.

If the recommendations of the Cave report are to be fulfilled then they will need to be underpinned by a considerable research programme. Additional investigative research to ensure interference management keeps in line with major technological developments will be necessary if the demand for new services can be introduced within the present allocated bands. In particular it is important that full advantage is taken of modern equipment designs with inbuilt interference reduction techniques. Finally the necessary research in such areas as propagation into the use of the higher microwave frequency bands (up to 140GHz) requires research programmes to be started in the short/medium term. The necessity for a structured research programme is paramount. It is therefore important that OFCOM be made responsible for implementing a research strategy which should be established by an independent committee in conjunction with OFCOM and reviewed annually.

11. Conclusions and recommendations

Although some of the spectrum issues raised in this report may be considered OFCOM internal management issues and therefore covered in the general statements in Part 1-1(3) that 'OFCOM may do anything which appears to them to be incidental or conducive to carrying out their functions -----' I believe some require a more specific and definitive statement in the Bill itself.


Part 2 Clause 110 (4) suggests that OFCOM 'may undertake research and development work --'. It is my considered opinion that this should be reworded to state that:-

'OFCOM will undertake research and development work to an agreed research strategy, set and reviewed annually by an independent committee and be held responsible to the secretary of state for its timely completion.'


With regard to clause 111 a review of the frequency plan is too woolly to be reviewed ' from time to time' as this is an invaluable document to industry and operators and its review should be at periods not greater than 2 years.


The importance and responsibility of OFCOM in providing Interference Management require specific reference. Clause 114 should be a mandatory requirement and not an advisory service. With regards to enforcement powers OFCOM should be required to establish and maintain regional offices and customer panels.


With regards to OFCOM relationship with operators and industry the Bill should make it a requirement for OFCOM to establish appropriate liaison committees.


The International responsibilities split at present between DTI and the RA need to be clearly defined within the Bill and it is suggested that on all spectrum technical issues OFCOM should act on behalf of the Secretary of State.

12. Final comment

Radio spectrum issues, frequency allocations and appropriate technical requirements of licences is at present dealt with by the RA. The RA would appear to be the odd spoke in the OFCOM wheel as primarily being a technical and engineering organisation including the necessary technical research capability to support these functions. Additionally they are the only one of the regulators which is a Government Agency with wide powers and as such, represents Government on spectrum and standards issues in the International fora, being the UK signatory to many International agreements. They also have significant enforcement powers and applications for search warrants and powers of seizure of apparatus may be more relevant to Government than OFCOM.

The committee may therefore wish to consider that OFCOM, considered by many to be primarily the regulator for the entire broadcast and media sector, would be more focussed and possibly stronger without the addition of the RA which would remain a government agency with only those staff associated with broadcast/media being integrated into OFCOM. The RA would of necessity, provide the appropriate technical and spectrum support to OFCOM, whilst itself concentrating on the major issues of spectrum efficiency, Interference management and International and European spectrum and standards harmonisation for the future. It is also worthy of consideration that the relationships and trust established over several decades by the RA not only in the UK but within Europe and the rest of the world with their equivalent Government bodies may take considerable time to re-establish by the much wider regulatory and non governmental OFCOM organisation.

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Prepared 31 July 2002